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In its summary, the Directorate stated: The proposed subject transaction conforms with the CRA's policy to not apply subsection 55(2) of the Act to internal reorganizations within a related group for loss consolidation purposes and recognizing that property retains its character on a rollover transaction between related parties is consistent with the CRA’s position in … 2014-0553731I7 that depreciable property should retain its character on wind-up. ...

The reason is that (a)(ii) of the ERDTOH definition only adds the Part IV tax if it generated a dividend refund to the connected payor out of its ERDTOH – and since the connected payor by assumption had not yet transitioned to the ERDTOH/NERDTOH regime, this would not be possible. ...

“[I]t is not necessarily the case that a qualifying property of an eligible entity will always conform to its legal title” – for example, the leasehold interest of a commercial tenant may represent only a portion of the legal title of the property. ...

Accordingly … business interruption insurance proceeds would generally be included in qualifying revenue and would generally not be considered an extraordinary item. ...

. … Although a leasing agreement is often referred to as a financing agreement, the CRA believes that the leasing agreement cannot be considered a true loan. ...

After indicating that where a taxation year has already been assessed on the basis of a fiscal period end, the Act does not have any provision that allows a reassessment to change the FPE, the Directorate went on to state: [T]he … [preamble] wording of subsection 249.1(1) indicates that the purpose of specifying a particular period of time as a fiscal period is that a corporation can choose, within the parameters specified under the subsection, a FPE for preparing its accounts for the purposes of assessment. ...

Conversely, if it was determined that TDH did not carry on a business, the excluded share exception would not apply – but s. ...

Conversely, if it was determined that the corporation did not carry on a business, the excluded share exception would not apply – but s. ...

Provided that … Mr. A is regarded as a tax resident of XXXXXXXXXX by virtue of Article 4(1) of the Treaty, the capital gain realized by Mr. ...

If a Treaty has no time-limits itself, then the usual domestic limits apply, for example, under s. 152 – again, subject to any changes provided in Bill C-20, that extend those delays for periods up to six months, but no later than December 31, 2020. ...